There have been few reports of Daily Telegraph readers convulsing over breakfast last week on finding a digest of the New York Times tucked into their papers. Many will hardly have noticed the insertion, for the difference between Anglo and American broadsheet journalism is slight, even between Tory Telegraph and conscience-wringing New York Times. Both favour the free world, the free market and the free expression of honestly-held views.

There is, however, one striking anomaly. Turn to the arts sections and you will find a divergence so extreme in tone and content that you will rub your eyes and wonder whether the two papers are discussing the same subject. Every serious British newspaper carries two, three or more pages of arts commentary and criticism which report, reflect and review a razzle of activity in a style which may be ponderous, or provocative, or purely piss-taking.

No American newspaper dares venture past the first of these ps. The tone in US arts coverage is uniformly respectful, uninquiring, inherently supportive. When the boss of Covent Garden takes an early bath, British papers roll out weeks of investigation, gossip and analysis. When the head of the Met decides (or is obliged) to step down, as Joseph Volpe did some weeks ago, he does so in a friendly interview with the New York Times which does not once inquire whether Volpe quit because he's pushing 65 or because his box-office has gone dead since 9/11.

The failure to challenge is a fundamental flaw in US arts journalism. The appointment of a visibly ailing James Levine to 'revitalise' the Boston's Symphony Orchestra was reported uncritically in the Globe. The shenanigans at Lincoln Center, where heads roll periodically and reconstruction plans flounder, are immune to the scrutiny that attends any public project of comparable prominence. As an arts place, Lincoln is off-limits to investigative journalism. Critics are free to diss Philadelphia's new concert hall and the New York Philharmonic's performance under Lorin Maazel, but any inquiry into the workings of these organisations is ruled out by unstated convention.

Disasters, where noted, are reported with extreme caution. What I describe as the death of classical recording, US newspapers refer to as a 'crisis' , implying that it is remediable. When I talk to American colleagues, we often agree about the facts of cultural decline. But the interpretation of those facts is as different as Arthur Rubinsteins Chopin from Sviatoslav Richters: same notes, worlds apart.

The source of our divergence is twofold. London is a newspaper town, with five serious dailies, four Sundays and one evening paper which cover all openings and stirrings. There arent many cities, noted Sam Bergman, a viola player from Minnesota, in which an orchestra can roll into town and overhear that there will be ten critics seated in the audience. Thats the beauty of playing London.

New York used to be like that. When Toscanini was conducting at the Met and Mahler at the Philharmonic, seven different papers had critics on duty. If a new Gershwin show came on against Cole Porter on Broadway, the world would wait up half the night for the first reviews to hit the street. A bar-line of artists awaiting their notices is a persistent Leitmotiv in Damon Runyon's tales, a driving force in Guys and Dolls.

But Manhattan's diversity was subsumed by consolidation. One daily after another was bought out or went under until, in the 1960s, New York, like most US cities, was left with just one paper to report the arts. This monopoly places an unhealthy burden on critics. If theirs is to be the only voice to pronounce on a new show or the fate of an institution, they are obliged to wear a mantle of responsibility that is antithetical to good journalism. A critic is licensed to get it wrong from time to time. Restrict that license and the reviews grow safe and solemn. An era of incorporation fostered a pontifical tone in American arts criticism.

Over the same era, America suffered the incorporation of many arts institutions. London has five international orchestras, three year-round opera companies, two ballet troupes, three international art galleries, two great engines of modern art at Tate and Saatchi, a National Theatre and too many smaller companies to count. New York has one monolith in each art form, two at most. A British paper can, if so minded, call for the closure of English National Opera, secure in the knowledge that another paper might take a very different view if only for the hell of it. The New York Times dare not challenge any arts institution because there is no outlet for any alternative view. If City Opera or the Met were to shut down as the results of an impetuous editorial, the Times would never be forgiven.

Where American arts journalism is shackled by civic responsibility, competitiveness, on our side, fosters friskier reviews and robust views. Even a flop like ENO's Rhinegold drew one or two favourable notices, precipitating the possibility of debate. In the US, there is scant opportunity for contradiction. I was asked a while back by the New York Times to submit an article comparing arts coverage in London and New York. After prolonged consideration, over several weeks, the article was rejected by an editor on the grounds that it would be 'odd to be criticizing ourselves in our own pages'. Odd? I expostulated. Surely that's what a free press is for. The Evening Standard, along with most British papers, regularly publishes articles which attack our editorial line or take issue with our columnists. That's how democracy is meant to work - but not, perhaps, in a monopoly culture.

Howell Raines, the New York Times editor who was toppled last year when one of his reporters, Jayson Blair, was caught making up stories, has attacked his former paper's loss of 'competitive metabolism' - its conviction that 'it's not news until we say it's news'. He calls this complacency 'manana journalism'. It could never prevail in the British press - which is not to say that all is rosy in our columns. Fierce competition often provokes a rush to judgement, a sense of perpetual crisis and a frantic chase for stories, sacrificing the process of reflective maturation.

Competition, however, entails the possibility of change. When one British paper upgrades its arts pages or dumbs down, the others take note and may follow suit. In the US, without competition, there is no incentive for change. Arts sections have grown duller and dumber as editors plug into celebrity culture. The Washington Post, almost alone among major metros, has held its nerve and maintained a flow of confident criticism.

What the Telegraph and New York Times have in common is that both are undergoing identity crisies - the Telegraph because of the uncertainty of its future ownership and the Times because lack of competition has bred rotten apples and bad journalism. Their vulnerability is hazardous to the arts. Both are vital organs in the world's cultural anatomy. Whatever else may be pressing on its conscience, the New York Times needs to remember that arts are more than just a magnet for premium-rate advertising. Arts is the section which projects a newspaper's responsiveness to creativity, its sensitivity to the world of ideas, its harmony with reflection, its common language with the most active of its readers.